Are you purchasing radio modules from manufacturers without checking if the RF modules are pre-approved in your target country list?
If the answer is no, or if the answer is yes and you would like to understand the importance of pre-approved RF modules, we prepared a short explanation about a great alternative that can help in your international regulatory compliance needs, the RF Modular Type Approval.
Well, to not run before walking, we first need to understand what a Radio Type Approval is.
The radio type approval is a mandatory procedure (in most countries) in which the designated country authority reviews technical and commercial information such as test reports, user manuals, internal pictures, external pictures, datasheets and more, and confirms that a product complies with the minimum set of regulatory and technical requirements and declares that the device can operate in the country without causing interference or breaching the provisions of its national frequency plan.
Usually, the radio type approvals are requested for the final devices but in some countries, it is allowed to have an alternative that can help to save time and costs and that we will be reviewing in this blog.
Well now that we have a basis on what a radio type approval is, we can understand what a modular approval is.
Well as its name states, the main goal of this type approval scheme is to confirm that the device’s RF functions work inside the established country regulations and that it will not cause interference. But where does the device main RF functions come from, the RF module!
Taking this in mind some countries have established the option to forego the requirement of certifying each final device and request the type approval for the RF module and allow that all host devices that use that module are also covered by the type approval certificate of conformity that the authority issues after their analysis.
Because applying logic, if the component that emits the radiofrequency functions is compliant with the regulations, therefore the devices that uses it must also be compliant with the regulations.
WHY SOME COUNTRIES ADOPTED THE RF MODULAR TYPE APPROVAL?
Well, the main phrase that will helps us to understand the reason of why some countries adopted this option is “work overload”.
Due to the increasing integration of RF functions in different types of electronic devices, requests to certify equipment with these functions have also been increasing, in many cases exceeding the processing capacity of some government authorities or generating efficiency gaps and delays in their internal processes.
This is why some regulatory authorities, in order to reduce the overload that they have been suffering in recent years and to provide the public in general with time efficient alternatives, gave the option that many devices can be covered by a single certificate, to avoid the need to carry out one, two, three, or even more final device requests for products that use the same RF module and only having to make one request for the radio frequency module.
Also, the FCC has a clear modular type approval policy that has been adopted by several countries, especially those in ITU Region 2.
THE CHALLENGE OF IN-COUNTRY TESTING
Some of the countries that allow the RF modular approval have in country testing as a mandatory requirement.
Usually when a host device manufacturer wants to make a modular approval for a module of a third-party module manufacturer in order for several of their final devices to be covered, the main challenge in the countries that require in-country testing is the difficulty to gather the module testing software and module test instructions, besides that some of the countries require to not only provide a module sample, but they also require that the sample must also be pre-configured and ready for testing.
Taking this in mind we highly suggest you that when purchasing a module from a third-party module manufacturer, you request in advance, their testing software and testing instructions, it’s one of those things that it’s better to have and not need than to need and not have, because sometimes the process to gather this information can take important amounts of time and if you are at the border of your planed final device launch/importation schedule, it could cause some delays.
Better yet, you may be able to leverage pre-existing type approvals from the RF module manufacturer for your own host device. In some cases this eliminates the type approval requirement for your device, but in many cases it simplifies or lessens the amount of local requirements, testing, or regulatory application fees.
Once you make a radio type approval request to get a certificate of conformity, some countries require that you put a mark/legend in the product or package label for the customer to be aware that the product is compliant with their regulations.
Well when leveraging modular approval you will also have to comply with these labeling requirements in the countries that request it, but with some minor differences (and depending on the perspective, with some advantages).
Let’s take as an example Argentina that requires in country-testing and has labeling requirements: if you make a modular approval instead of having to put the regular RAMATEL label you will have to put a label that states that the device contains an already certified module as shown in the examples of the picture below:
This type of labeling alternative for modular approval is quite similar in countries that have labelling requirements and allow modular approval (of course, each country/entity has its own requirements, but the purpose of indicating that the equipment contains a certified module remains)
An advantage of this is that since most countries allow you to add these labels through stickers, it is possible to generate a sticker with the same label stating that it contains a certified device used to transmit and/or receive radio signals and paste it to all the products that contain the module.
As you have noticed, the modular certification sounds quite advantageous, so we proceed to list a summary of some of its advantages below:
- Reduces processing times in case of multiple model type approval requests.
- Reduces homologation regulatory fees.
- Limits the number of samples needed and may eliminate the need of sending a host product sample unit for local testing.
- In most cases it facilitates labeling by enabling the use of the same compliance mark for several product model numbers.
HOW TO APPLY IT
By following the steps above, you should be well on your way to taking advantage of the modular type approval scheme. We strongly urge all manufacturers implementing a wireless radio module for the first time to have the proper conversations with the RF module supplier in regards to international type approval, to ensure that you have the tools necessary to enable global market access in your target countries.
If your internal compliance team does not have ample experience on a global scale, we strongly encourage your company to reach out to a third party like Approve-IT that can guide you through the complex type approval landscape.
We encourage feedback and thoughts in the comments section. Thank you!